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Animal testing for cosmetics in China – It’s complicated!
When establishing our position on companies that sell their products via e-commerce (i.e. online sales) to China, we reached out to the Humane Society International, Choose Cruelty Free and PETA to get expert advice.
According to Choose Cruelty Free (CCF), information from their contacts in China has confirmed that animal testing does not occur via e-commerce channels. CCF allows companies that sell into China via e-commerce only to be eligible for the CCF accreditation as the products are sold directly to the consumer and therefore do not require regulatory animal testing. Subject to CCF’s stringent accreditation, if they find evidence to a company’s products being tested on animals in China, their accreditation will be void.
The PETA Beauty Without Bunnies Liaison confirmed with several sources in contact with the Chinese regulatory authorities that post-market testing is not, and has not been, done with tests on animals. Instead, authorities sometimes pull products and do an analysis of ingredients to make sure the ingredients are exactly as they’re listed.
The Humane Society International told us that some e-commerce products could avoid pre-market animal tests, and the likelihood of post-market animal test is very low. However, there is no documented evidence that animal testing won't occur. E-commerce is an emerging market so the policies and rules around cosmetics and animal testing could change in the near future.
Recent updates to Chinese law concerning cosmetics now make it possible to register to sell domestically in China and avoid animal testing.1 Several specific requirements need to be met, and the information available on the website of the responsible Chinese government agency is quite complex!2
But based on information from The Leaping Bunny,3 as of May 2021, products can be exempt from pre-market animal testing if:
- they do not have efficacy claims to them (like teeth whitening products, sunscreen, or hair dye).
- they are marketed for adults, not specifically for children or pregnant people.
- they only contain ingredients that are known and accepted by the Chinese authority.
- the company (and their suppliers) have a certificate of Good Manufacturing Practice from their local government.
- the local Responsible Person shall not be listed as a key supervision target (i.e., cannot have a criminal record or any open investigations).
The Leaping Bunny China Qualification Program, in cooperation with Knudsen&CRC (based in Shanghai), offers guidance and supervision for entering products in the Chinese market and maintaining cruelty-free status.4 In dedication to cruel and unnecessary animal testing, Knudsen&CRC are offering to screen the ingredients list of cruelty-free brands free of charge, as there is no actual “accepted ingredients list”. The information has to be gathered individually about each ingredient.
We include companies in our Cruelty Free Guide that sell cosmetics in China via e-commerce only, but if laws change and we find evidence of animal testing occurring, then these companies will be removed from our guide immediately. We will include companies that sell commercially in China and are avoiding animal testing.
More information on animal testing for cosmetics in China
What are cosmetics?
In China, cosmetics are considered “daily used chemical products applied on the surface of any part of the human body (such as skin, hair, nails and lips) by way of smearing, spraying or other similar methods to keep the body clean, to get rid of undesirable smells, to protect the skin, to make up the face and to increase the beauty of the appearance.”
Cosmetic products in China are divided into two categories.5
- Special use cosmetics: Whitening products, hair growth products, hair dyes, hair perming products, depilating products, breast beauty products, slimming products, deodorants, freckle-removing products, and sunscreens.
- Non-special use cosmetics: Everything else! I.e. non-special use shampoos and lipsticks.
Are there any other exceptions to animal testing requirements?
Apart from selling products to China via e-commerce only, there are a few other exceptions:
- If a company only sells products in Hong Kong6 or Taiwan,7it can avoid animal testing. While both have not banned animal testing of cosmetics, they do not require them either.
So what cosmetic products still require animal testing by Chinese law?
- Special-use cosmetics: these have efficacy claims, like hair dye, hair perms, anti-freckle and whitening products, sunscreen, and anti-hair loss products; products for children are also classed as special cosmetics.
- Cosmetics using materials that are not part of the accepted list.
- Products by companies who are not certified as following Good Manufacturing Practices by their local government.
What about products that aren’t cosmetics?
If a product is not considered a cosmetic, whether animal testing will be required depends on relevant regulations. For detergents, usually, animal testing will not be involved.
Toothpaste is a special case. It is included as a cosmetic. Further testing will be required if it has additional claims like whitening.
Note: This article was written based on the advice of multiple experts and in-depth research. But these laws can change, and the information in this article is subject to change should we become aware of new information.